LI Program News - December 21, 2017

December 21, 2017

FCC Approves Lifeline Program Order

On December 1, 2017, the Federal Communications Commission (FCC) released Bridging the Digital Divide for Low-Income Consumers, which includes a Fourth Report and Order, Order on Reconsideration, Memorandum Opinion and Order, Notice of Proposed Rulemaking (NPRM), and Notice of Inquiry (NOI).

The order sections include:

Eliminating the Benefit Port Freeze

Limiting the enhanced Lifeline benefit of $25 per month to consumers who live on rural, Tribal lands, and receive service from a facilities-based service provider

Clarifications about: applying the Lifeline benefit to the End User Common Line charges, the National Verifier will not provide copies of certification forms to service providers, and broadband service that qualify for Lifeline support

The NLAD Snapshot is taken on the 1st day of each month at 6 a.m. ET, and includes all active subscribers from the previous month. For example, downloading the Snapshot Report for data month - November (11/2017) - will show all active subscribers as of December 1.

As a reminder, starting with the August 2017 data month, service providers' subscriber counts on the FCC Form 497 must be less than or equal to their NLAD Snapshot Report. If the subscriber count claimed on the form is greater than the number of subscribers on the Snapshot Report, the form will not be processed which may cause a delayed payment.

USAC reminds service providers to keep subscriber records up-to-date in NLAD (as required by the Lifeline Program rules) to avoid incorrect subscriber counts on the NLAD Snapshot Report taken on the first day of the month.

2017 FCC Form 555 Available Now; Due January 31

The 2017 version of FCC Form 555, the "Annual Lifeline Eligible Telecommunication Carrier Certification Form," is available in the E-File system. The FCC Form 555 is due January 31, 2018 to USAC, state regulatory commissions, and the FCC.

Service providers use FCC Form 555 to report the results of the annual recertification process, and make additional certifications. Service providers must submit one form per SAC.

The 2017 version of the form is re-designed to accommodate the new rolling recertification process, and service providers will report recertifications by status and method per month. This year's form will only report recertification results from July to December; service providers do not need to report results for anniversary dates from January to June 2017, as these subscribers were in the "transition period". Some filings will be impacted by hurricanes Harvey, Irma, or Maria.

Also note, ETCs will not have access to the "Single Form Entry" method when the system initially rolls out; the data entry feature will be available in early January 2018. In the meantime, ETCs can use the "Bulk Upload Entry" method for single and/or multiple SPINs/SACs to report their subscribers' recertification results.

The form must be completed and submitted using E-File. USAC recommends logging into E-File to confirm user entitlements as soon as possible, and using one of the recommended internet browsers: Chrome, Firefox, or Internet Explorer 10.

Available FCC Form 555 Resources:

Recording of the webinar, Changes to FCC Form 555, which includes a walkthrough of the newly-designed form (originally presented July 12, 2017)

Accounting for Hurricane Relief on FCC Form 555

The FCC granted temporary hurricane relief for areas impacted by Hurricanes Harvey, Irma, and Maria, from September 8, 2017 to February 28, 2018 for affected disaster areas in Florida and Georgia, and from September 7, 2017 to March 31, 2018 for Puerto Rico and the U.S. Virgin Islands. All other areas in Florida received temporary hurricane relief from September 8, 2017 to December 7, 2017.

The temporary relief for affected disaster areas in Florida, Georgia, Puerto Rico, and the U.S. Virgin Islands suspended the non-usage rules and granted temporary recertification waivers for affected subscribers, which impacts how Lifeline service providers should report their recertification results on FCC Form 555. The temporary relief for all other areas in Florida only waives the recertification deadlines.

Service providers serving areas covered under the temporary relief will not have complete Form 555 data for the affected anniversary months because of the temporary recertification waivers issued for subscribers in the affected hurricane areas. When reporting your Form 555 results, if your SAC(s) has any subscribers that are covered under a temporary recertification waiver, withhold the data for the entire anniversary month on the Form 555 until you have completed the recertification process for all subscribers in the September anniversary month. For instance, if only 5 subscribers were subject to the temporary recertification waiver, you would withhold all of the data for the entire anniversary month, until you have completed the recertification process for all affected subscribers.

Service providers will be required to revise their 2017 Form 555 and include complete data for the affected anniversary months after they have completed the recertification process for affected subscribers. Even if you are withholding data for certain anniversary months to account for the temporary recertification waivers, you must still submit the FCC Form 555 by January 31, 2018.

National Verifier Soft Launch Postponed

On December 1, 2017, the Federal Communications Commission released a Public Notice announcing that the National Verifier's soft launch is postponed to early 2018.

The National Verifier system is subject to compliance with the Federal Information Security Management Act (FISMA), and the postponed soft launch will allow time to complete all FISMA requirements.

During the soft launch, service providers in the initial launch states (Colorado, Mississippi, Montana, New Mexico, Utah, and Wyoming) can begin using the National Verifier portal and paper forms to validate consumer eligibility for the Lifeline Program. This soft launch period is voluntary for service providers - they can choose to check consumer eligibility through the National Verifier or by using their legacy processes.

December 2017 is the Final Data Month for FCC Form 497

December 2017 (January 1 snapshot) is the final data month that service providers will use FCC Form 497 to claim reimbursements. Afterward, service providers will use the new Lifeline Claims System process to claim reimbursement, and will only use FCC Form 497 to revise claims from the December 2017 data month and earlier.

The Lifeline Claims System process must be completed online. In preparation for this new process, USAC recommends setting up user entitlements as soon as possible.

California, Michigan, and New York Streamlined Eligibility Waivers Extended

The FCC extended the California streamlined eligibility waiver from October 31, 2017 to April 30, 2018, the Michigan streamlined eligibility waiver from December 31, 2017 to June 30, 2018, and the New York streamlined eligibility waiver from December 1, 2017 to April 30, 2018. Service providers can continue to rely on these states' eligibility processes until the waivers expire or until the state's process aligns with the federal eligibility criteria, whichever is sooner.

If California, Michigan or New York does not update its eligibility verification process to align with the federal eligibility criteria by the relevant deadline, service providers will be responsible for ensuring that subscribers in that state enrolled or recertified after the deadline meet the federal eligibility criteria.

Minimum Service Standards Increased on December 1, 2017

The 2016 Lifeline Modernization Order established minimum service standards for the Lifeline Program that increase over time.

Starting on December 1, 2017, the minimum service standards are:

Mobile voice: At least 750 minutes per month

Mobile broadband: Speed of 3G or better with a usage allowance of at least 1GB

Fixed broadband: Speed of 15/2 Mbps or better with a usage allowance of at least 250 GB

Protecting Subscribers' Personally Identifiable Information (PII)

Subscribers share personally identifiable information or PII as part of the Lifeline Program's application and recertification processes, including their name, address, last four digits of their Social Security number (SSN) and date of birth (DOB). Service providers are obligated under FCC rules to keep subscriber PII data secure.

As a reminder:

Do not send USAC your consumer's DOB or SSN. Instead, use their subscriber ID (found in NLAD) when communicating with USAC about a specific subscriber.

Email is not a secure transmittal method for PII. Do not use email to send a subscriber's PII to USAC.

Always use the minimum amount of PII that is necessary to complete your task or job.

If personal information is necessary to identify the subscriber, please encrypt the document containing the subscriber PII with a password and provide the password separately from the password-protected document. Please provide us with a contact number to call to get the encryption password. USAC will call the specified number to get the password, please do not email the password.

2018 Webinar Schedule Now Available

The 2018 schedule for the monthly Lifeline Program Update Webinars is now available on our website. The Lifeline Program Update webinar is generally scheduled for the second Wednesday of the month, discussing a variety of topics including the National Verifier, NLAD, and Lifeline rules and orders.

Join us on Wednesday, January 10 for our next monthly Lifeline Program webinar. In January, we will provide an overview of the FCC Form 555 and the new Lifeline Claims System process.

The Universal Service Administrative Company (USAC) is dedicated to achieving universal service. As a not-for-profit corporation designated by the Federal Communications Commission (FCC), we administer the $10 billion Universal Service Fund. With the guidance of the FCC policy, we collect and deliver funding through four programs that are focused specifically on places where broadband and connectivity needs are acute.